Electronic Records
Management and Preservation Pose Challenges Gao ID: GAO-03-936T July 8, 2003The difficulties of managing, preserving, and providing access to the vast and rapidly growing volumes of electronic records produced by federal agencies present challenges to the National Archives and Records Administration (NARA), the nation's recordkeeper and archivist. Complex electronic records are being created in volumes that make them difficult to organize and keep accessible. These problems are compounded as computer hardware, application software, and even storage media become obsolete, as they may leave behind electronic records that can no longer be read. As a result, valuable government information may be lost. GAO was requested to testify, among other things, on NARA's recent actions to address the challenges of electronic records management, including its effort to address the problem of preserving electronic records by acquiring an advanced Electronic Records Archive (ERA).
As reported in GAO's past work, most electronic records--including databases of major federal information systems--remained unscheduled: that is, their value had not been assessed, and their disposition--to destruction or archives--had not been determined. In addition, records of historical value were not being identified and provided to NARA; as a result, they were at risk of loss. NARA has begun to address these problems by taking steps to improve federal records management programs; among other things, it has (1) updated guidance to reflect new types of electronic records, (2) devised a strategy for raising awareness among senior agency management of the importance of good federal records management, and (3) devised a comprehensive approach to improving agency records management that includes inspections and identification of risks and priorities. Through these and other actions, NARA is making progress, but its approach to improving records management does not include provisions for using inspections to evaluate the efficacy of its governmentwide guidance, and an implementation plan for the approach has yet to be established. Without these elements, the risk is increased that federal records management problems will persist. In addition to its efforts to improve records management, NARA is also acquiring ERA as a means to archive all types of electronic records and make them accessible. GAO found, however, that NARA faces significant challenges in acquiring ERA, a major information system. While NARA has made progress in building its organizational capabilities for acquiring major information systems, it has not developed adequate policies, plans and practices to guide the ERA acquisition or established the means to track the cost and schedule of the project. Unless NARA addresses these and other issues, the ERA system may not meet user expectations, and NARA may not have the information required to control the cost of the system or the time it will take to complete it.
GAO-03-936T, Electronic Records: Management and Preservation Pose Challenges
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United States General Accounting Office:
GAO:
Testimony:
Before the Subcommittee on Technology, Information Policy,
Intergovernmental Relations, and the Census, Committee on Government
Reform, House of Representatives seseRRepresenRepresentative:
For Release on Delivery :
Expected at 10 a.m. EDT Tuesday, July 8, 2003:
Electronic Records:
Management and Preservation Pose Challenges:
Statement of Linda D. Koontz Director, Information Management Issues:
GAO-03-936T:
GAO Highlights:
Highlights of GAO-03-936T, a testimony before the Subcommittee on
Technology, Information Policy, Intergovernmental Relations, and the
Census, Committee on Government Reform, House of Representatives
Why GAO Did This Study:
The difficulties of managing, preserving, and providing access to the
vast and rapidly growing volumes of electronic records produced by
federal agencies present challenges to the National Archives and
Records Administration (NARA), the nation‘s recordkeeper and
archivist. Complex electronic records are being created in volumes
that make them difficult to organize and keep accessible. These
problems are compounded as computer hardware, application software,
and even storage media become obsolete, as they may leave behind
electronic records that can no longer be read. As a result, valuable
government information may be lost. GAO was requested to testify,
among other things, on NARA‘s recent actions to address the challenges
of electronic records management, including its effort to address the
problem of preserving electronic records by acquiring an advanced
Electronic Records Archive (ERA).
What GAO Found:
As reported in GAO‘s past work, most electronic records”including
databases of major federal information systems”remained unscheduled:
that is, their value had not been assessed, and their disposition”to
destruction or archives”had not been determined. In addition, records
of historical value were not being identified and provided to NARA; as
a result, they were at risk of loss. NARA has begun to address these
problems by taking steps to improve federal records management
programs; among other things, it has (1) updated guidance to reflect
new types of electronic records, (2) devised a strategy for raising
awareness among senior agency management of the importance of good
federal records management, and (3) devised a comprehensive approach
to improving agency records management that includes inspections and
identification of risks and priorities. Through these and other
actions, NARA is making progress, but its approach to improving
records management does not include provisions for using inspections
to evaluate the efficacy of its governmentwide guidance, and an
implementation plan for the approach has yet to be established.
Without these elements, the risk is increased that federal records
management problems will persist.
In addition to its efforts to improve records management, NARA is also
acquiring ERA as a means to archive all types of electronic records
and make them accessible. GAO found, however, that NARA faces
significant challenges in acquiring ERA, a major information system.
While NARA has made progress in building its organizational
capabilities for acquiring major information systems, it has not
developed adequate policies, plans and practices to guide the ERA
acquisition or established the means to track the cost and schedule of
the project. Unless NARA addresses these and other issues, the ERA
system may not meet user expectations, and NARA may not have the
information required to control the cost of the system or the time it
will take to complete it.
www.gao.gov/cgi-bin/getrpt?GAO-03-936T.
To view the full product, click on the link above.
For more information, contact Linda Koontz at (202) 512-6240 or
koontzl@gao.gov.
[End of section]
Mr. Chairman and Members of the Subcommittee:
I appreciate the opportunity to participate in the Subcommittee's
hearing on the challenges of records management in an electronic era.
As you know, agencies are increasingly moving to an operational
environment in which electronic--rather than paper--records are used to
document their activities and business processes. This migration to an
increasingly electronic environment is likely to accelerate in light of
the E-Government Act of 2002, which encourages the expansion of
electronic government.[Footnote 1]
This transformation is leading to improvements in the way federal
agencies work and interact with each other and with the public, but it
has also led to the generation of vast and rapidly growing volumes of
electronic records. These records need to be properly managed, as they
provide documentation and information that are necessary for essential
government functions and for protecting government and citizen
interests. Also, a small percentage of documents and other records are
sufficiently significant that they must be preserved in archives for
the historical record.[Footnote 2]
Overall responsibility for the government's electronic records lies
with the National Archives and Records Administration (NARA),[Footnote
3] whose mission is twofold: (1) oversight of records management, which
governs the life cycle of records (creation, maintenance and use, and
disposition), and (2) archiving, which is the permanent preservation of
documents and other records of historical interest. In carrying out
these missions, NARA and agencies use a process known as scheduling to
assess the value of records and determine their disposition.
As requested, in my remarks today, I will begin by providing some
perspective on records management and its importance to the government
in today's environment. In addition, I will:
* describe the challenges that the government faces in managing and
preserving electronic records,
* summarize the results of our June 2002 report on electronic records
management issues,
* provide information on NARA's actions since we issued our report and
assess its progress in responding to the recommendations we made to
improve governmentwide records management, and:
* assess NARA's efforts to acquire an advanced electronic record
archive (ERA), intended to preserve and provide access to electronic
records.
Our evaluation of records management challenges and issues is based on
our June 2002 report, entitled Information Management: Challenges in
Managing and Preserving Electronic Records. To update NARA actions
since our report, we analyzed key documents and plans, and we
interviewed appropriate agency officials. Our assessment of NARA's
efforts to acquire ERA reflects the results of ongoing work, the
results of which will be reported in August 2003.
We performed our update work from June to July 2003 in accordance with
generally accepted auditing standards.
Results in Brief:
The rapid evolution of information technology is creating challenges in
managing and preserving electronic records. Complex electronic records
are increasingly being created in a decentralized environment and in
volumes that make it difficult to organize them and make them
accessible. Further, storage media themselves are affected by the dual
problems of obsolescence and deterioration: for example, few computers
today have disk drives that can read information stored on 8 or 5¼-inch
diskettes, even if the diskettes themselves remain readable. These
problems are compounded as computer hardware and application software
become obsolete, as they may leave behind electronic records that can
no longer be read. Unless these challenges are addressed, valuable
government information may be lost forever.
Our past work has shown that while NARA has responded to the challenges
associated with managing and preserving electronic records, most
electronic records--including databases of major federal information
systems--remained unscheduled, and records of historical value were not
being identified and provided to NARA; as a result, they were at risk
of loss. A number of factors contributed to this condition:
* NARA acknowledged that its policies and processes on electronic
records had not yet evolved to reflect the modern recordkeeping
environment: records created electronically in decentralized
processes.
* Records management programs were generally afforded low priority by
federal agencies. A related issue was that agency management had not
given priority to acquiring the more sophisticated and expensive
information technology required to manage records in an electronic
environment.
* NARA was also not performing systematic inspections of agency records
programs. Such inspections are important as a means to evaluate
individual agency records management programs, assess governmentwide
progress in improving records management, and identify agency
implementation issues and areas where guidance needs to be
strengthened.
We recommended that NARA develop strategies for raising agency
management awareness of the importance of records management and for
performing systematic inspections.
In the year since our report was issued, NARA has taken steps to
improve its guidance and address the lack of technology tools. In
response to our recommendations, it has devised a reasonable strategy
for raising awareness among senior agency management. In addition, it
has devised a comprehensive approach to improving agency records
management that includes inspections and identification of risks and
priorities, but its approach does not include provisions for using
inspections to evaluate the efficacy of its governmentwide guidance,
and an implementation plan for the approach has yet to be established.
Until NARA fully addresses the need to assess and improve agency
records management programs and develop an implementation plan, the
risk is increased that records management programs will continue to
show the weaknesses that led to the scheduling and disposition problems
that we and NARA described in earlier work.
To address the problems associated with preserving electronic records
in a rapidly changing technological environment, NARA is acquiring ERA,
an advanced archiving system whose acquisition presents significant
challenges. First, while NARA has made progress in strengthening its
organizational capabilities for acquiring major information systems,
these capabilities are not fully established. For example, NARA has
completed some elements of an information security program; however,
several key areas--such as developing individual system security plans-
-have not yet been addressed. Second, the policies, plans, and
practices that NARA is using to acquire ERA do not in many cases
conform to standards or to applicable federal acquisition guidance.
Finally, NARA is unable to objectively track the cost and schedule of
the ERA project. Unless NARA improves its acquisition planning, the
risk is increased that the ERA system will fail to meet user
expectations, and that NARA will not have the information required to
control the cost of the system or the time it will take to complete it.
In view of these risks, we have recommended that NARA address
weaknesses in its acquisition policies, plans, and practices and its
ERA schedule.
Background:
NARA's mission is to ensure "ready access to essential evidence" for
the public, the president, the Congress, and the Courts. NARA's
responsibilities stem from the Federal Records Act,[Footnote 4] which
requires each federal agency to make and preserve records that:
* document the organization, functions, policies, decisions,
procedures, and essential transactions of the agency and:
* provide the information necessary to protect the legal and financial
rights of the government and of persons directly affected by the
agency's activities.
Federal records must be managed to ensure that the information that
they contain is available when needed. According to NARA, without
effective records management, the records needed to document citizens'
rights, actions for which federal officials are responsible, and the
historical experience of the nation will be at risk of loss,
deterioration, or destruction.
Records management is defined as the policies, procedures, guidance,
tools and techniques, resources, and training needed to design and
maintain reliable and trustworthy records systems. Records must be
managed throughout their life cycle: from creation, through maintenance
and use, to final disposition. Temporary records--those used in
everyday operations but lacking historic value--are ultimately
destroyed. Permanent records--those judged to be of historic value--are
preserved through archiving.
With NARA's oversight and assistance, each agency is responsible for
managing its own records at all phases of the life cycle, with the
exception of the archiving of permanent records (which is NARA's
responsibility).
NARA Is Responsible for Oversight of Records Management and for
Archiving:
NARA is responsible for:
* issuing records management guidance;
* working with agencies to implement effective controls over the
creation, maintenance, and use of records in the conduct of agency
business;
* providing oversight of agencies' records management programs; and:
* providing storage facilities for certain temporary agency records.
The Federal Records Act also authorizes NARA to conduct inspections of
agency records and records management programs.
Records Are Managed through Scheduling:
NARA works with agencies to identify and inventory records; to appraise
their value; and to determine whether they are temporary or permanent,
how long the temporary records should be kept, and under what
conditions both the temporary and permanent records should be kept.
This process is called scheduling. No record may be destroyed unless it
has been scheduled. Thus, for temporary records the schedule is of
critical importance, because it provides the authority to dispose of
the record after a specified time.
Records are governed by schedules that are either (1) specific to an
agency or (2) general--that is, common to several agencies or across
the government. According to NARA, records covered by general records
schedules make up about a third of all federal records. For the other
two thirds, NARA and the agencies must agree upon specific records
schedules. Once a schedule has been approved, the agency must issue it
as a management directive, train employees in its use, apply its
provisions to temporary and permanent records, and evaluate the
results.
Guidance Addresses Electronic Records:
While the Federal Records Act covers documentary material regardless of
physical form or media, records management and archiving were until
recently largely focused on handling paper documents. With the advent
of computers, both records management and archiving have had to take
into account the creation of records in varieties of electronic
formats.
NARA's basic guidance for the management of electronic records is in
the form of a regulation at 36 CFR Part 1234. This guidance is
supplemented by the issuance of periodic NARA bulletins and a records
management handbook, Disposition of Federal Records.
For electronic records, NARA's guidance sets forth two basic
requirements.
* First, agencies are required to maintain an inventory of all agency
information systems. The inventory should identify (1) the system's
name, (2) its purpose, (3) the agency programs supported by the system,
(4) data inputs, sources, and outputs, (5) the information content of
databases, and (6) the system's hardware and software environment.
* Second, NARA requires agencies to schedule the electronic records
maintained in their systems. Agencies must schedule those records
either under specific schedules (completed through submission and
approval of Standard Form 115, Request for Records Disposition
Authority) or pursuant to a general records schedule. NARA relies on
this combination of inventory and scheduling requirements to ensure
that management of agency electronic records is consistent with the
Federal Records Act.
NARA has also established a general records schedule for electronic
records. General Records Schedule 20 (GRS 20) authorizes the disposal
of certain categories of temporary electronic records. It has been
revised several times over the years in response to developments in
information technology, as well as legal challenges.
GRS 20 applies to electronic records created both in computer centers
engaged in large-scale data processing and in the office automation
environment. GRS 20 authorizes the disposal of certain types of
electronic records associated with large data base systems, (such as
inputs, outputs, and processing files), as well as the deletion of the
electronic version of records on word processing and electronic mail
systems once a recordkeeping copy has been made. Since most agency
recordkeeping systems are paper files, GRS 20 essentially authorizes
agencies to destroy E-mail and word-processing files once they are
printed. (Recall that records not covered by a general records schedule
may not be destroyed unless authorized by a records schedule that has
been approved by NARA.):
GRS 20 does not address many common products of electronic information
processing, particularly those that result from the now prevalent
distributed, end-user computing environment. For example, although the
guidance addresses the disposition of certain types of electronic
records associated with large databases, it does not specifically
address the disposition of electronic databases created by
microcomputer users. In addition, GRS 20 does not address more recent
forms of electronic records such as Web pages and portable document
format (PDF) files.[Footnote 5]
NARA Archives Permanent Records of Historical Interest:
As the nation's archivist, NARA accepts for deposit to its archives
those records of federal agencies, the Congress, the Architect of the
Capitol, and the Supreme Court that are determined to have sufficient
historical or other value to warrant their continued preservation by
the U.S. government. NARA also accepts papers and other historical
materials of the Presidents of the United States, documents from
private sources that are appropriate for preservation (including
electronic records, motion picture films, still pictures, and sound
recordings), and records from agencies whose existence has been
terminated.
To ensure that permanent electronic records are preserved, each agency
must transfer electronic records to NARA in accordance with the
agency's records disposition schedule. NARA accepts for archiving
electronic records that are in text-based formats, such as databases
and certain text-based geographic information system (GIS)[Footnote 6]
files. In addition, NARA accepts E-mail records and attachments,
several forms of scanned images of text files, and PDF files. It does
not accept Web pages, word processor files, or relational databases.
(Although NARA does not as yet accept such files for archiving, they
must still be scheduled.)[Footnote 7]
Agencies Are Beginning to Automate Management of Electronic Records:
In response to the difficulty of manually managing electronic records,
agencies are turning to automated records management applications to
help automate electronic records management lifecycle processes. The
primary functions of these applications include categorizing and
locating records and identifying records that are due for disposition,
as well as storing, retrieving, and disposing of electronic records
that are maintained in repositories. Also, some applications are
beginning to be designed to automatically classify electronic records
and assign them to an appropriate records retention and disposition
category.
The Department of Defense (DOD), which is pioneering the assessment and
use of records management applications, has published application
standards and established a certification program.[Footnote 8] DOD
standard 5015.2, endorsed by NARA, includes the requirement that
records management applications acquired by DOD components after 1999
be certified to meet this standard.[Footnote 9]
NARA Is Currently Pursuing Initiatives Related to Electronic Records
Management:
NARA is pursuing other interrelated efforts that address records
management (including electronic records). Three major initiatives are:
* NARA's effort on Redesign of Federal Records Management;
* the Electronic Records Management initiative, one of 25 e-government
initiatives sponsored by the Office of Management and Budget (OMB),
and:
* the acquisition of an advanced Electronic Records Archives (ERA).
In 2000, NARA began a three-stage effort to redesign federal records
management. First, in 2001, NARA produced a report based on information
on federal records management that it collected and analyzed.[Footnote
10] Second, it used this report as a starting point to revise the
regulations, policies, and processes for managing federal records and
to develop a set of strategies to support federal records management.
As a result of this analysis, in July 2002 NARA issued a draft proposal
for the redesign of federal records management. Third, based on
comments received on the proposal, it is developing a redesigned
records scheduling, appraisal, and accessioning process, as well as
prototype and functional requirements for automated tools for the
redesigned process. The redesign is planned as a multiyear process
(2003 to 2006), during which NARA intends to address the scheduling and
appraisal of federal records in all formats.
The overall purpose of the Electronic Records Management (ERM)
initiative is to help agencies better manage their electronic records,
so that records information can be effectively used to support timely
and effective decision making, enhance service delivery, and ensure
accountability. The initiative is intended to provide a variety of
tools to address immediate and longer term agency needs. NARA is the
managing partner agency for the overall ERM initiative.
The goals for the advanced ERA system are that it will be able to
preserve and provide access to any kind of electronic record, free from
dependency on any specific hardware or software, so that the agency can
carry out its mission into the future. NARA plans for ERA to be a
distributed system, allowing storage and management of massive record
collections at a variety of installations, with accessibility provided
via the Internet. NARA is planning to build the system in five
increments, with the last increment scheduled to be complete in 2010.
Inherent Features of Electronic Records Make Management and
Preservation Challenging:
The rapid evolution of information technology makes the task of
managing and preserving electronic records complex and costly. Part of
the challenge of managing electronic records is that they are produced
by a mix of information systems, which vary not only by type but by
generation of technology: the mainframe, the personal computer, and the
Internet. Each generation of technology brought in new systems and
capabilities without displacing the older systems.[Footnote 11] Thus,
organizations have to manage and preserve electronic records associated
with a wide range of systems, technologies, and formats. These records
are stored in specific formats and cannot be read without software and
hardware--sometimes the specific types of hardware and software on
which they were created.
Several factors contribute to the challenge of managing and preserving
electronic records:
* Massive volumes of electronic data require automated solutions.
Electronic records are increasingly being created in volumes that pose
a significant technical challenge to our ability to organize them and
make them accessible. For example, among the candidates for archiving
are military intelligence records comprising more than 1 billion
electronic messages, reports, cables, and memorandums, as well as over
50 million electronic court case files. Managing such large volumes is
clearly not possible without automation.
* Control of electronic records is difficult in a decentralized
computing environment.
The challenge of managing electronic records significantly increases
with the decentralization of the computing environment. In the
centralized environment of a mainframe computer, it is easier to
identify, assess, and manage electronic records than it is in the
decentralized environment of agencies' office automation systems, where
every user is creating electronic files that may constitute a formal
record and thus should be preserved.
* The complexity of electronic records precludes simple transfer to
paper.
Electronic records have evolved from simple text-based files to complex
digital objects that may contain embedded images (still and moving),
drawings, sounds, hyperlinks, or spreadsheets with computational
formulas. Some portions of electronic records, such as the content of
dynamic Web pages, are created on the fly from databases and exist only
during the viewing session. Others, such as E-mail, may contain
multiple attachments, and they may be threaded (that is, related E-mail
messages are linked into send-reply chains). These records cannot be
converted to paper or text formats without the loss of context,
functionality, and information.
* Obsolescent and aging storage media put electronic records at risk.
Storage media are affected by the dual problems of obsolescence and
decay. They are fragile, have limited shelf life, and become obsolete
in a few years. For example, few computers today have disk drives that
can read information stored on 8-or 5¼-inch diskettes, even if the
diskettes themselves remain readable.
* Electronic records are dependent on evolving software and hardware.
Electronic records are created on computers with software ranging from
word-processors to E-mail programs. As computer hardware and
application software become obsolete, they may leave behind electronic
records that cannot be read without the original hardware and software.
Past GAO Work Highlighted Electronic Records Challenges:
In June 2002,[Footnote 12] we reported that NARA had responded to the
challenges associated with managing and preserving electronic records.
However, most electronic records--including databases of major federal
information systems--remained unscheduled, and records of historical
value were not being identified and provided to NARA; as a result, they
were at risk of loss. A number of factors contributed to this
condition:
* NARA acknowledged that its policies and processes on electronic
records had not yet evolved to reflect the modern recordkeeping
environment: records created electronically in decentralized
processes.
* Records management programs were generally afforded low priority by
federal agencies. A related issue was that agency management had not
given priority to acquiring the more sophisticated and expensive
information technology required to manage records in an electronic
environment.
* NARA was also not performing systematic inspections of agency records
programs. Such inspections are important as a means to evaluate
individual agency records management programs, assess governmentwide
progress in improving records management, and identify agency
implementation issues and areas where guidance needs to be
strengthened.
We also provided some confirmation of NARA's findings regarding records
scheduling and disposition: our review at four agencies (Commerce,
Housing and Urban Development, Veterans Affairs, and State) elicited a
collective estimate that less than 10 percent of mission-critical
systems were inventoried. As a result, for these four agencies alone,
over 800 systems had not been inventoried, and the electronic records
maintained in them had not been scheduled.[Footnote 13] Scheduling the
electronic records in a large number of major information systems
presents an enormous challenge, particularly since it generally takes
NARA, in conjunction with agencies, well over 6 months to approve a new
schedule.
Failure to inventory systems and schedule records places these records
at risk. The absence of inventories and schedules means that NARA and
agencies have not examined the contents of these information systems to
identify official government records, appraised the value of these
records, determined appropriate disposition, and directed and trained
employees in how to maintain and when and how to dispose of these
records. As a result, temporary records may remain on hard drives and
other media long after they are needed or could be moved to less costly
forms of storage. In addition, there is increased risk that these
records may be deleted prematurely while still needed for fiscal,
legal, and administrative purposes. Further, the lack of scheduling
presents risks to the preservation of permanent records of historic
significance.
Guidance on Management of Electronic Records Was Not Up to Date:
NARA acknowledged in 2001 that its policies and processes on electronic
records had not yet evolved to reflect the modern recordkeeping
environment: records created electronically in decentralized
processes.[Footnote 14] Despite repeated attempts to clarify its
electronic records guidance through a succession of bulletins, the
guidance was incomplete and confusing. It did not provide comprehensive
disposition instructions for electronic records maintained in many of
the common types of formats produced by federal agencies, including Web
pages and spreadsheets. To support their missions, many agencies had to
maintain such records--often in large volumes--with little guidance
from NARA.
Agency Records Management Programs Had Low Priority and Did Not Have
Technology Tools:
NARA's study concluded that records management was not even "on the
radar scope" of agency leaders. Further, records officers had little
clout and did not appear to have much involvement in or influence on
programmatic business processes or the development of information
systems designed to support them. New government employees seldom
received any formal, initial records management training. One agency
told NARA that records management was "number 26 on our list of top 25
priorities.":
Further, records management is generally considered a "support"
activity. Since support functions are typically seen as the most
dispensable in agencies, resources for and focus on these functions are
often limited. Also, as NARA's study noted, federal downsizing may have
negatively affected records management and staffing resources in
agencies.
In our June 2002 report, we recommended that the Archivist of the
United States address the priority problem by developing a documented
strategy for raising agency senior management awareness of and
commitment to records management principles, functions, and programs.
Related to the priority issue is the need for appropriate information
technology tools to respond to the technical challenge of electronic
records management: for electronic records to be managed effectively,
agencies require a level of technology that was not necessary for
paper-based records management programs. Unless management is focused
on records management, priority is not given to acquiring or upgrading
the technology required to manage records in an electronic environment.
Agencies that do invest in electronic records management systems tend
to do so because they value good records management and have a critical
need to retrieve information efficiently. In other agencies, despite
the growth of electronic media, agency records systems are
predominantly in paper format rather than electronic. According to
NARA's study, many agencies were either planning or piloting
information technology initiatives to support electronic records
management, but their movement to electronic systems is constrained by
the level of financial support provided for records management.
Inspections of Agency Records Management Programs Were Limited:
NARA is responsible, under the Federal Records Act, for conducting
inspections or surveys of agency records and records management
programs and practices. Its implementing regulations require NARA to
select agencies to be inspected (1) on the basis of perceived need by
NARA, (2) by specific request by the agency, or (3) on the basis of a
compliance monitoring cycle developed by NARA.[Footnote 15] In all
instances, NARA is to determine the scope of the inspection. Such
inspections provide not only the means to assess and improve individual
agency records management programs but also the opportunity for NARA to
determine overall progress in improving agency records management and
identify problem areas that need to be addressed in its guidance.
In 2000, NARA changed its method of performing inspections: rather than
performing a small number of comprehensive agency reviews, it
instituted an approach that it refers to as "targeted assistance." NARA
decided that its previous approach to inspections was basically flawed,
because it could reach only about three agencies per year,[Footnote 16]
and because the inspections were often perceived negatively by
agencies, resulting in a list of records management problems that
agencies then had to resolve on their own. Under the targeted
assistance approach, NARA works with agencies, providing them with
guidance, assistance, or training in any area of records management.
However, we pointed out in our June 2002 report that this approach,
although it may improve records management in the targeted agencies, is
not a substitute for systematic inspections and evaluations of federal
records programs. Targeted assistance has significant limitations
because it is voluntary and, according to NARA, initiated by agency
request. Thus, only agencies requesting assistance are evaluated, and
the scope and the focus of the assistance are not determined by NARA
but by the requesting agency.
In light of these limitations, we recommended in June 2002 that the
Archivist develop a documented strategy for conducting systematic
inspections of agency records management programs to (1) periodically
assess agency progress in improving records management programs and
(2) evaluate the efficacy of NARA's governmentwide guidance.
NARA Is Continuing to Respond to Records Management Challenges, but Its
Progress on Inspections is Limited:
Since June 2002, NARA has taken steps to strengthen its guidance, to
address the low priority accorded to records management programs and
the associated lack of technology tools, and to revise its approach to
inspections as part of a comprehensive strategy for assessing agencies'
management of records. However, NARA's plans to implement its
comprehensive new strategy are not yet complete. Although the strategy
describes a reasonably systematic approach that allows NARA to focus
its resources appropriately and to use inspections and other
interventions to assess and improve federal records management, it does
not yet include a description of how NARA will establish an ongoing
program.
NARA Is Improving Records Management Guidance:
Since our 2002 report, NARA has taken steps to update its guidance on
electronic records management in various areas. For example, although
36 CFR Part 1234, the basic guidance on electronic records, has not
been updated to reflect new types of electronic records, NARA has
produced a variety of guidance on electronic records. A new General
Records Schedule, GRS 24, "Information Technology Operations and
Management Records," was issued on April 28, 2003. In addition,
"Records Management Guidance for PKI-Unique Administrative Records,"
which was jointly developed by NARA and the Federal Public Key
Infrastructure Steering Committee's Legal/Policy Working Group, was
issued on March 14, 2003. As part of its e-government initiative, NARA
has just released guidance on evaluating funding proposals for
electronic records management systems through capital planning
processes.
NARA has also supplemented its disposition guidance[Footnote 17] as a
result of the project on transfer of permanent electronic records under
its e-government initiative: this guidance covers transferring
permanent E-mail records and attachments, several forms of scanned
images of text files, and PDF, and it expanded the methods by which
agencies could transfer electronic records to NARA for archiving. NARA
is also planning to expand the capability of its current systems for
archiving electronic records by accommodating additional electronic
record formats and volumes. However, according to NARA, agencies have
not yet transferred electronic records in these formats to NARA; these
records may not be scheduled or may not yet be eligible for transfer.
In addition, as part of the policy analysis in its effort to redesign
federal records management, NARA has stated that it plans to identify
policies, procedures, regulations, and guidance that would need to be
modified in light of the proposed redesign.
Efforts Continue to Raise the Priority of Agency Records Management
Programs and Address Technology Issues:
In response to our recommendation that it develop a documented strategy
for raising agency senior management awareness of records management,
NARA devised a strategy intended to raise awareness of the importance
of agency records management. The strategy includes two goals:
* increased senior-level awareness of the importance of records
management, particularly electronic records management, across the
federal government and in specific agencies, and:
* increased senior-level understanding of how effective records
management programs support the business needs of specific agencies and
the federal government as a whole.
As part of its strategy, NARA identified a number of activities that
its senior leaders will conduct, including briefing agency program
leaders on the importance of records and information management in
general and on specific issues (such as electronic record keeping
requirements, litigation exposure, and vital records), participating in
establishing or closing out certain targeted assistance agreements, and
pursuing promotional activities such as making speeches and holding
conferences.
NARA has also developed an implementation plan, which establishes
goals, timeframes, and required resources for fiscal year 2003. For
example, the plan contains a goal of conducting six agency briefings by
the end of September; three have been completed to date, and a fourth
has been scheduled for mid-July. A similar implementation plan for
fiscal year 2004 is to be developed by September 1.
NARA's strategy for raising senior agency management awareness appears
reasonable, and if carried out effectively could help to mitigate the
problem of the low priority given to records management.
Since our June 2002 report, some steps have also been taken to address
the lack of technology tools to manage electronic records. In January
2003, NARA recommended that agencies use version 2 of DOD standard
5015.2, which sets forth a set of requirements for records management
applications, including that they be able to manage records regardless
of their media. The effort to promulgate this standard was part of the
electronic information management standards project under the ERM
initiative. Under the standard, DOD is to certify records management
applications as meeting the standard; as of the end of June 2003, DOD
had certified 43 applications. The availability of applications that
conform to the standard may be helpful in encouraging agencies to adopt
records management systems that address electronic records.
NARA Plans Comprehensive Approach to Improving Agency Records
Management:
In response to its own mission needs and our recommendations of June
2002 regarding its inspection program, NARA has documented a new
strategy for assessing agencies' management of records. This strategy
is described in draft documents that describe NARA's plans for setting
priorities and for conducting inspections and studies. The new approach
is now being piloted with the Department of Homeland Security; the
results of the pilot--expected by September 30, 2003--will determine
whether it is extended governmentwide.
The main features of the draft strategy are as follows:
* NARA will evaluate agencies and work processes in terms of risk to
records, implications for legal rights and accountability, and the
quantity and value of the permanent records; it will focus its
resources on high-priority areas. This process of assessing risks and
priorities will involve NARA staff with subject-matter and agency
expertise, and it will address records management governmentwide.
* NARA plans to use a variety of means to address areas identified for
attention through its risk and priority assessment. Among the means
being considered are targeted assistance, records management studies,
and inspections.[Footnote 18] The strategy indicates that NARA has
changed its approach to targeted assistance: Rather than using it only
when an agency requests assistance, NARA intends to recommend that an
agency accept targeted assistance when NARA has identified records
management issues at that agency that require attention. In addition,
NARA plans to perform studies on records management best practices as a
means not only to encourage good records management practices
throughout government, but also to recognize agencies whose records
management programs have exemplary features. According to the strategy,
inspections will be conducted only under exceptional circumstances,
when the risk to records is deemed high, and after other means have
failed to mitigate risks (e.g., targeted assistance, training, and so
on).
* NARA intends to focus on the core functions of the federal
government, rather than on individual agencies. It will use as its
starting point the business areas defined in the Business Reference
Model[Footnote 19] of the Federal Enterprise Architecture.[Footnote 20]
By focusing on the Business Reference Model's broad activities and work
processes, which cut across agency lines, NARA may inspect a single
agency or a group of agencies in one line of business.
Although NARA's strategy appears to be a reasonably systematic approach
that allows it to focus its resources appropriately and to use
inspections and other interventions to assess and improve federal
records management, it is not yet complete. Specifically, the draft
strategy does not yet include a description of how NARA will establish
an ongoing program. For example, the priority assessment plan does not
indicate whether NARA will revise its risk identification process as
circumstances warrant, or if this a single-time occurrence. NARA
officials have said that the agency will update its priority and risk
assessments periodically, but this is not yet reflected in the plan.
Further, the strategy states that the results of studies may be used to
improve guidance, but it does not create a similar feedback loop for
inspection results. While records management guidance may benefit from
the "best practices" identified in studies, inspection results could
also identify areas where guidance needs to be clarified, augmented,
and strengthened. Finally, no implementation plan or schedule for this
new strategy has yet been devised.
Without a strategy that provides for establishing an ongoing program
that includes a feedback cycle, as well as complete implementation
plans that fully reflect that strategy, NARA's efforts to assess
records management programs may not provide it with the information
that it needs to improve its guidance and to support its redesign of
federal records management.
NARA's Acquisition of ERA Continues to Face Risks:
In addition to its efforts to improve records management across the
government, NARA is also acquiring ERA as a means to archive all types
of electronic records and make them accessible, regardless of changes
to hardware and software over time. However, NARA faces significant
challenges in acquiring ERA. ERA will be a major information system;
NARA has no previous experience in acquiring major information systems.
Further, no comparable electronic archive system is now in existence,
in terms of either complexity or scale. Finally, technology necessary
to address some key requirements of ERA is not commercially available
and will have to be developed. In light of these challenges, NARA will
face significant difficulties in its ERA acquisition unless it
addresses:
* its information technology (IT) organizational capabilities;
* ERA system acquisition policies, plans, and practices; and:
* its ability to control ERA's cost and schedule.
NARA has indicated that it needs to strengthen its IT organizational
capabilities and has been taking steps to do so in three key areas:
* IT investment management provides a systematic method for agencies to
minimize risks while maximizing the return on IT investments.
* An enterprise architecture provides a description--in useful models,
diagrams, and narrative--of the mode of operation for an agency. It
provides a perspective on agency operations both for the current
environment and for the target environment, as well as a transition
plan for sequencing from the current to the target environment. Managed
properly, an enterprise architecture can clarify and help optimize the
dependencies and relationships among an agency's business operations
and the underlying IT infrastructure and applications that support
these operations.
* Information security is an important consideration for any
organization that depends on information systems to carry out its
mission. Our study of security management best practices found that
leading organizations manage their information security risk through an
ongoing cycle of risk management.
NARA has made progress in strengthening these capabilities, but these
efforts are incomplete. For example, NARA has improved its IT
investment management. However, although it is continuing to develop an
enterprise architecture, NARA does not plan to complete its target
architecture in time to influence the ERA system definition and
requirements. In addition, it has completed some elements of an
information security program, but several key areas have not yet been
addressed (such as individual system security plans), and NARA has not
assessed the security risks to its major information systems.
In addition, NARA has developed policies, plans, and practices to guide
the ERA acquisition, but these do not consistently conform to industry
standards and federal acquisition guidance. NARA has chosen to follow
Institute of Electrical and Electronics Engineers (IEEE)
standards[Footnote 21] in developing its policies, plans, and
practices. Examples of these include (1) a concept of operations that
describes the characteristics of a proposed system from the users'
viewpoint and provides the framework for all subsequent activities
leading to system deployment, (2) an acquisition strategy that
establishes how detailed acquisition planning and program execution
will be accomplished, and (3) a risk management plan to identify
potential problems and adjusting the acquisition to mitigate them.
However, key policy and planning documents are missing elements that
are required by the standards and federal acquisition guidance: for
example, the ERA acquisition strategy did not satisfy 15 of 32 content
elements required by the relevant IEEE standard.
Further, NARA is unable to track the cost and schedule of the ERA
project. The ERA schedule does not include all program tasks and lacks
a work breakdown structure, which would include detail on the amount of
work and resources required to complete each task.
Unless NARA can address these issues, the risk is increased that the
ERA system will fail to meet user expectations, and that NARA may not
have the information required to control the cost of the system or the
time it will take to complete it.
In light of these risks, our briefing included recommendations to NARA
to address the weaknesses in its acquisition policies, plans and
procedures and to improve its ability to adequately track the project's
cost and schedule.
In summary, NARA and the federal government face significant challenges
in managing electronic records, which are largely due to the rapidly
changing technological environment. While NARA is responding to these
challenges with its various initiatives, much work remains to be done.
Specifically, NARA has implemented our recommendation to address the
low priority given to records management programs. The agency's
advocacy strategy, if implemented effectively, could help raise
awareness of the importance of records management governmentwide.
However, NARA has not fully responded to our recommendation for a
revitalized inspection program. Further, while it is making progress in
building its capacity to acquire a major system, it has not developed
adequate policies, plans, and practices to guide the ERA acquisition or
established an effective means to track the project's cost and
schedule. Until NARA fully addresses these challenges, the success of
the ERA project remains at risk, the government may not be able to gain
control over the massive numbers of electronic records that continue to
grow every day, and permanent records of historical value may be
subject to loss.
Mr. Chairman, this concludes my statement. I would be pleased to answer
any questions that you or other members of the subcommittee may have at
this time.
Contact and Acknowledgements:
If you should have any questions about this testimony, please contact
me at (202) 512-6222 or via E-mail at koontzl@gao.gov. Other major
contributors to this testimony included Tim Case, Barbara Collier,
Mirko Dolak, and Elena Epps.
(310375):
FOOTNOTES
[1] Electronic government refers to the use of technology, particularly
Web-based Internet applications, to enhance the access to and delivery
of government information and services to citizens, business partners,
employees, other agencies, and other entities.
[2] Of the total number of federal records, less than 3 percent are
designated permanent.
[3] NARA's regulations implementing the Federal Records Act are found
at 36 CFR 1200-1280.
[4] 44 U.S.C. chapters 21, 29, 31, and 33.
[5] PDF is a proprietary format of Adobe Systems, Inc., that preserves
the fonts, formatting, graphics, and color of any source document,
regardless of the application and platform used to create it.
[6] A geographic information system is a computer system for capturing,
storing, checking, integrating, manipulating, analyzing, and
displaying data related to positions on the Earth's surface. Typically,
a GIS is used for handling maps of one kind or another. These might be
represented as several different layers where each layer holds data
about a particular kind of feature (e.g., roads). Each feature is
linked to a position on the graphical image of a map.
[7] NARA's requirements for the transfer of agency electronic records
are provided through 36 CFR Part 1228. NARA's Web site provides further
guidance on this topic under the heading Permanent E-Records Transfers
to NARA Deliverables. (http://www.archives.gov/records_management/
initiatives/transfer_to_nara.html)
[8] Department of Defense, Design Criteria Standard for Electronic
Records Management Software Applications, DOD 5015.2-STD (November
1997) (http://www.dtic.mil/whs/directives/corres/html/50152std.htm).
[9] DOD 5015.2-STD requires that records management applications be
able to manage records regardless of their media.
[10] SRA International, Inc., Report on Current Recordkeeping Practices
within the Federal Government (Dec. 10, 2001) (http://www.nara.gov/
records/rkreport.html). This document reports results from two sources:
a recordkeeping study performed by NARA's contractor, SRA
International, and a series of records system analyses performed by
NARA staff.
[11] International Council on Archives, Guide for Managing Electronic
Records from an Archival Perspective (Paris: February 1997).
[12] U.S. General Accounting Office, Information Management: Challenges
in Managing and Preserving Electronic Records, GAO-02-586 (Washington,
D.C.: June 17, 2002).
[13] According to information collected by the Office of Management and
Budget in November 1999 as part of the federal government's effort to
assess the Year 2000 computing challenge, 6,435 mission-critical
systems were reported at the 24 major agencies. For the 4 agencies we
reviewed, the number of mission-critical systems was reported to be
907. Subcommittee on Government Management, Information, and
Technology, House Committee on Government Reform, Federal Government
Earns B+ on a Final Y2K Report Card, news release (Washington, D.C.:
Nov. 22, 1999).
[14] National Archives and Records Administration, An Overview of Three
Projects Relating to the Changing Federal Recordkeeping Environment
(January 2001) (http://www.nara.gov/records/rmioverview.html).
[15] CFR 1220.54 (a).
[16] Between 1996 and 2000, NARA performed 16 inspections of agency
records management programs; only 2 of the 24 major executive
departments or agencies were reviewed, with most evaluations focused on
component organizations or independent agencies.
[17] These requirements are found in 36 CFR Part 1228.
[18] Other means include standard and tailored training programs,
certification programs for records managers, and various forms of
advocacy.
[19] The Business Reference Model is a function driven framework for
describing the business operations of the federal government
independent of the agencies that perform them.
[20] The Federal Enterprise Architecture is a business-based foundation
that provides a common framework for governmentwide improvements in key
areas such as performance measurement and e-government. The Office of
Management and Budget began development of the Federal Enterprise
Architecture in February 2002.
[21] The Institute of Electrical and Electronics Engineers, 12207.0
Standard for Information Technology--Software Life Cycle Processes;
12207.1 Standard for Information Technology--Software Life Cycle
Processes--Life Cycle Data; and 12207.2 Standard for Information
Technology--Software Life Cycle Processes--Implementation
Considerations.
